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30 June 2015

No consultation document survives first contact with its stakeholders (without the need for further elaboration)

Last Friday, as we were putting the finishing touches to plans for the launch of the consultation by the English, Welsh and Northern Irish funding bodies on future arrangements for quality assessment, the feeling was one of relief that we had finally reached the moment of publication.

I sat down to write the first full draft of the consultation document on Good Friday. It feels an age ago. Since then there have been many, many discussions with colleagues from across the UK sector, and even more redrafting sessions. There were leaks. There were rumours, some reasonably accurate and some not even close. And, of course, along the way there was a general election that produced a majority government with a manifesto commitment on teaching excellence to implement.

It was fascinating to watch the initial responses to the publication. First the series of embargoed press releases from sector bodies came through over the weekend. Then the publication yesterday morning of pre-prepared press and blog articles. And then the twitter flurry – my favourite twitter exchange invoked Eric Partridge’s Usage and Abusage in defence of a perceived grammatical mistake in the consultation document.

Post-publication, we’ve started to understand more clearly the issues that people feel strongly about, and also those where we’ve obviously not been sufficiently clear in the consultation document. Some highlights:

On student engagement: ‘I sincerely hope the stream of good practice from the sector in these areas isn’t side-lined’. Absolutely not. We’re trying to design a quality assessment system that delivers the things that matter to students – assurances that their degree is credible and reasonably comparable to those from other institutions, and a good academic experience and broader outcomes – in ways that recognise that meaningful ‘partnership’ and ‘engagement’ are essential. And we’re clear that we need to work closely with students and their representatives as we do more work on the detailed design of our proposals.

On ‘independence’ or ‘co-regulation’ and ‘co-ownership’: These terms are used in different ways and in defence of competing arguments. The Times, 30 June 2015 (‘Universities to rate their own performance’) sees it as about independence from the sector. The sector see it as independence from government. Perhaps ‘co-regulation and ownership – though producing an arguably flawed result in the form of today’s system – might one day look far more preferable than what follows it.’ For the record, HEFCE’s independence from government is protected by the 1992 Act, the same act of parliament that gives us a statutory duty to assess quality. The consultation proposals retain a commitment to ‘co-regulation’: the operation of assurance processes by autonomous institutions, and the testing of these assurances by the funding body as part of its statutory duty. Perhaps ‘co-ownership’ is a bit trickier? I’m left wondering whether ‘co-ownership’ and ‘independence’ – from the sector, in this version of the argument – are irreconcilable.

On lifting the burden of cyclical review visits: ‘The burden will not be lifted, it will merely shift from external review by QAA to external review by HEFCE (with added burden of annual submissions)’. Again, no. The current purpose of the HEFCE Assurance Review is to test the reliability of the assurances provided by a governing body about financial sustainability, governance, and student data. We’re proposing to adopt the same approach to collecting and testing assurances about academic output standards and the student academic experience. This represents a different kind of engagement with institutions, one that will be designed to confirm that autonomous institutions are fulfilling their own obligations. We know that we will need to tweak the current HAR process to make sure that it is credible and provides the right sort of expertise. But we are clear that this will be a very different beast to the HER, with a different purpose and a different way of engaging with institutions.

But what about the TEF? The discussion about quality assessment started back in the autumn and the proposals published yesterday are the culmination of lengthy debate with a wide range of interested parties. The Government’s work to develop and implement a TEF is at a much earlier stage. But HEFCE has been working hard to ensure that we understand the relationship between these two elements of a broad-based quality system and are confident that they are complementary. We don’t intend to end up in a position with two separate strands of ‘external cyclical review’, so our quality assessment proposals have been designed to leave this space open for the TEF. But, of course, as the TEF develops, and as we hear responses to our consultation, we’ll revisit some of these issues.

So, are we ‘pressing the quality reset button’? I’m not sure about that, but we are clear that ‘refresh’ is definitely necessary if we are to provide the assurances that students and other stakeholders want, without imposing unhelpful bureaucratic burdens on an increasingly diverse sector that needs to compete in a more marketised environment.

The consultation document’s first formal engagement with the world has revealed the need for further elaboration and explanation, but the proposals themselves are holding up. And the purpose of the consultation is to set out proposals and then to gather and test responses. And then to think some more. I think it’s going to be a long summer… .